Medical insurance benefits cannot be deducted from compensation under the Motor Vehicles Act.

The claimant sought compensation under Section 166 of the Motor Vehicles Act, 1988, for injuries sustained when a motorcycle struck her while she was walking on 17 September 2015.

The Tribunal found the motorcycle rider negligent and awarded Rs.1,99,620, including Rs.49,513 for medical expenses—the amount the claimant said she had paid after receiving Rs.1,30,000 under a medical-insurance claim.

The claimant appealed, seeking enhancement and contending that the medical-insurance payment should not reduce compensation for medical expenses.

1. Whether the Rs.1,30,000 received under the claimant’s medical-insurance policy could be deducted from compensation payable for medical expenses under the Motor Vehicles Act.

2. Whether the Tribunal’s award under the various heads of compensation required enhancement.

Section 166 of the Motor Vehicles Act, 1988, provides for claims for compensation arising from motor-vehicle accidents, and Section 173 provides for an appeal against a Tribunal’s award.

Applying New India Assurance Company Ltd. v. Dolly Satish Gandhi & Another, 2026 INSC 498, the Court held that sums received under medical or Mediclaim insurance are not deductible from compensation under the Motor Vehicles Act, including compensation for medical expenses. The Court noted that statutory compensation and contractual insurance benefits stand on different footing.

The Court accepted that the claimant had received Rs.1,30,000 under medical insurance and applied Dolly Satish Gandhi to hold that this contractual benefit could not be deducted from her statutory compensation.

It found the Tribunal’s other awards—including for disability, pain and suffering, transport, nourishment, attendant charges, future treatment and loss of earnings—proper and reasonable, and declined to alter them.

It therefore revised the medical-expenses figure in its award table to Rs.1,30,000 and fixed total compensation at Rs.2,80,100.

The insurer was directed to deposit the enhanced compensation, less any amount already deposited, within six weeks; the claimant may withdraw it on application to the Tribunal.